ML20207K299
| ML20207K299 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/19/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 0483C, 483C, NUDOCS 8701090384 | |
| Download: ML20207K299 (3) | |
Text
..
TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 SN 157B Lookout Place SG DEC29 P 3 : P3 DEC 19 %
U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/86-43 AND 50-328/86 SUPPLEMENTAL RESPONSE TO VIOLATION NOS.
50-327/86-43-02 and 50-328/86-43-02 Enclosed is our response to Gary G. Zech's September 12, 1986 letter to S. A. White which transmitted Notice of Violation 50-327/86-43-02 and 50-328/86-43-02.
This supplemental response is provided in accordance with Gary G. Zech's December 9, 1986 letter to S. A. White requesting additional details concerning our corrective steps to avoid further violations. is our supplemental response to the subject Notice of Violation. contains the list of commitments contained in Enclosure 1.
We do not recognize any other actions described herein or the subject inspection report as commitments.
If you have any questions, please get in touch with M. R. Harding at 615/870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VAL Y AUTHORITY R. Gridley, Director Nuclear Safety and Licensing Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. G. G. Zech Director, TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 t
l j
8701090394 861219 L
PDR ADOCK 0500 7
An Equal Opportunity Employer d
4 ENCLOSURE 1 SUPPLEMENTAL RESPONSE-NRC-OIE INSPECTION REPORT
_~Jf NOS. 50-327/86-43-02 AND 50-328/86-43-02 GARY G. ZECH'S LETTER TO S. A. WHITE t
DATED SEPTEMBER 12, 1986 4
In accordance with our original response to Notice of Violation 327, 328/86-43-02 (transmitted by letter from R. L. Gridley to Dr. Grace dated October 31, 1986), a review of changes to instructions using the administrative instruction (AI)-4, Appendix G, Instruction Change Form was initiated. That review along with the review of AI-4 indicated that a clarification of the AI-4 requirements was needed.
AI-4 will be revised by April 1, 1987 to allow changes to instructions when it is discovered that a change is needed to complete work in progress or to meet near-term schedule target dates and there is not sufficient time to process a change through normal routing.
These changes will be processed using Appendix G.
With these changes, AI-4 will continue to, meet the requirements of Sequoyah technical specifications 6.8.2 and 6.8.3 in that nonintent changes will continue to require approval by two SR0s or a SRO and a cognizant supervisor before the change may be implemented. The change must also be reviewed by PORC and approved by the Plant Manager or his designee within 14 days of the date the change was implemented. Also, intent changes to instructions will continue to require (1) approval of a SRO or cognizant supervisor, (2) review and concurrence of QA Staff, and (3) review by PORC and approval of Plant Manager or his designee before being implemented. This process was discussed at length with Watts Bar Nuclear Plant NRC Resident, Morris Branch, on l
November 18, 1986.
To ensure correctness and explicitness of work instructions for Postmaintenance' Tests (PMTs) specified on Work Requests (WRs) and to reduce the use of the phrase " perform the applicable portion," the maintenance supervisors, on November 19, 1986, were informed that if explicit PMT work instructions cannot be determined in the planning of a WR and the phraca is used, then before its implementation, a cognizant responsible person (i.e.,
Engineering Supervisor, Maintenance Planner, General Foreman, Foreman, Shift Engineer, SRO, C-4 level Lead Engineer) must review the work document and define the specific steps of any " applicable portions" of necessary instructions.
This was subsequently reviewed by Maintenance Planners in their weekly meeting and a copy of the response was posted on
..e bulletin board in l
the planning area.
As a follow-up to these instructions, a memorandum was issued on December 16, 1986 to Plant Operations and Maintenance personnel from the Plant Manager describing these requirements. The requirements will also be included in Sequoyah Standard Practice (SQM)-2 or another plant instruction on PMT by April 1, 1987.
To improve the timeliness of making permanent revisions to instructions, information from INPO and other utilities is being evaluated.
Since instruction revisions are presently within Sequoyah's PORC Charter, any significant change in the instruction revision process must be coordinated with resolution of the present issues concerning the conduct of PORC activities. We have established a target date of April 1, 1987 to finalize an improvement plan for PORC's objectives, responsibilities, and conduct of activities.
0483c MY c
--w a
a,
ENCLOSURE 2
_~!
LIST OF COMMITMENTS
'i l
1.
Revise AI-4 by April 1, 1987 to allow changes to instructions when it is o
discovered that a change is needed to complete work in progress or to meet near-term schedule target dates and there is not sufficient time to process a change through normal routing.
2.
Revise SQM-2 or another plant instruction on PMT by April 1, 1987 to include the requirements for using the statement " perform the applicable portion."
3.
Finalize an improvement plan for PORC's objectives, responsibilities, and conduct of activities including evaluation of information from INPO and other utilities to improve,the timeliness of making permanent revisiens to instructions by April 1, 1987.
0483c I
i l
i
- a e' nr ^
-ar, -, n
.a
+
+g,,4,,. %-y p & s'
,,,' ; +9
...